Lewis-Ranwell v G4S Health Services (UK) Ltd & Ors [2022] EWHC 1213 (QB) (20 May 2022)

Lewis-Ranwell v G4S Health Services (UK) Ltd & Ors [2022] EWHC 1213 (QB) (20 May 2022)

The claim for negligence against the First, Third, and Fourth Defendants is barred by the doctrine of illegality (ex turpi causa), as the losses claimed are inextricably linked to the claimant's own unlawful acts (killings) for which he was acquitted by reason of insanity but still bears legal and moral responsibility; public policy, consistency, and coherence between criminal and civil law require that compensation not be awarded for consequences of such acts, regardless of criminal responsibility.

Citation
[2022] EWHC 1213
Parties
Claimant: Alexander Lewis-Ranwell; First Defendant: G4S Health Services (UK) Limited; Second Defendant: Chief Constable of Devon and Cornwall Police; Third Defendant: Devon Partnership NHS Trust; Fourth Defendant: Devon County Council
Jurisdiction
England and Wales
Judgment Date
20 May 2022
Procedural Posture
Civil Negligence and Human Rights Claim / Application to Strike Out Claim (preliminary)
Outcome
Claim struck out against First, Third, and Fourth Defendants (negligence claims barred); Human Rights Act claims not struck out.
Legal Topics
Negligence, Illegality Defence (ex Turpi Causa), Mental Health Assessment, Human Rights Act Claims, Public Policy in Tort, Causation, Insanity in Criminal Law
Tort Law Mental Health Law Human Rights Law Civil Procedure Negligence Illegality Defence (ex Turpi Causa) Mental Health Assessment Human Rights Act Claims +3 more

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Parties

Alexander Lewis-Ranwell

Claimant

G4S Health Services (UK) Limited

First Defendant

Chief Constable of Devon and Cornwall Police

Second Defendant

Devon Partnership NHS Trust

Third Defendant

Devon County Council

Fourth Defendant

Procedural Posture

Civil Negligence and Human Rights Claim / Application to Strike Out Claim (preliminary)

Legal Issues

  1. 1 Whether the illegality defence (ex turpi causa) bars a negligence claim by a claimant acquitted of murder by reason of insanity
  2. 2 Whether the claim discloses reasonable grounds for bringing a negligence action against the First, Third, and Fourth Defendants
  3. 3 Whether public policy precludes compensation for losses resulting from the claimant's own unlawful acts while insane

Ratio Decidendi

The claim for negligence against the First, Third, and Fourth Defendants is barred by the doctrine of illegality (ex turpi causa), as the losses claimed are inextricably linked to the claimant's own unlawful acts (killings) for which he was acquitted by reason of insanity but still bears legal and moral responsibility; public policy, consistency, and coherence between criminal and civil law require that compensation not be awarded for consequences of such acts, regardless of criminal responsibility.

Court Disposition

Claim struck out against First, Third, and Fourth Defendants (negligence claims barred); Human Rights Act claims not struck out.

Orders

  • Negligence claims against G4S Health Services (UK) Limited, Devon Partnership NHS Trust, and Devon County Council struck out under CPR r3.4(2)(a)
  • Human Rights Act claims may proceed